Presentation Transcript

1. TCEQ Environmental Trade Fair & Conference May 6-7, 2014 MUNICIPAL WASTEWATER PERMITS TCEQ Environmental Trade Fair & Conference 2014 Dex Dean & Becca Moore 512-239-4671
2. TOPICSOUTLINE Part I: The Permitting Process Applying and Tracking Administrative Review Water Quality Assessment Technical Review The Draft Permit Part II: General Municipal Wastewater Permitting Information Types of Applications Permit Classifications TLAPs 210 Reuse
3. Applying and Tracking Administrative Review Water Quality Assessment Technical Review The Draft Permit Part I: The Permitting Process PART I – The PERMITTING PROCESS
4. APPLICATION FORMS The forms that are needed to apply are as follows: 10053-inst: Instructions for Completing the Domestic Wastewater Permit Application 10053: Domestic Wastewater Permit Application (PDF) 10054: Domestic Wastewater Permit Application Technical Report (PDF)
5. If I have questions… Call (512) 239-4671 If I have lots of questions or unique issues… Consider pre-application meeting with TCEQ staff If I need to renew my existing permit… Submit application 180 days before the existing permit expires APPLICATION HELP
6. A typical permit application flows from the applicant to: The Applications Review & Processing Team The Water Quality Assessment Section A pretreatment reviewer (if required) A permit coordinator The Chief Clerk’s Office The EPA (if required) The permittee, as an issued permit The permit coordinator and the applicant have active roles in communicating with the public and TCEQ staff. It is normal to be contacted by several different people from the TCEQ. Applications Team Draftto Applicant Issued Permit NOD &NORI NAPD EPA / Public Comments Water Quality Assessment Pretreatment Permit Coordinator Chief Clerk’s Office APPLICANT PERMITTING PROCESS Region & Enforcement
7. Don’t get bogged down… Respond to Notices of Deficiency Publish both public notices and return documents (30 days each) Check for bilingual requirements Check accuracy and formatting Complete/correct affidavit and verification Review draft permit and send approval or comments
8. HELPFUL WEBSITE RESOURCES The TCEQ home page (http://www.tceq.texas.gov) has several helpful tools. You can: Search the whole website [top-right corner], Browse information designed for the public, for business, or for local governments [left-hand side, choose Public, Businesses, or Governments] Browse general information about water regulation [right-hand side, choose WATER], Browse general information about permits or registrations [left-hand side, choose Permits, Registrations], Track an application, view notices, make comments, see enforcement actions [right-hand side, choose View Pending Matters and File Documents], Search for information about a specific permit [left hand side, choose from the options under Search Central Registry , -or- center, choose Find the status of a permit, license] , Find application forms [left-hand side, choose Forms].
9. ADMINISTRATIVE REVIEW: AVOID COMMON ERRORS Fill out all contact information Sign the form Provide complete maps Arrange to have the application displayed in a public building Update the location description (as needed) Provide a complete landowner list (as needed) Provide a complete landowner list (as needed)
10. Compliance with the Texas Surface Water Quality Standards Endangered species impact Water quality modeling Biomonitoring (Whole Effluent Toxicity) Groundwater impact evaluation (for TLAP permits) WATER QUALITY ASSESSMENT REVIEW
11. WATER QUALITY ASSESSMENT:SEGMENT AND BASIN SPECIFIC ISSUES Impaired Segments – 303(d) list Total Maximum Daily Loads (TMDLs) Endangered Species Lake Rules (30 TAC Chapter 311) Geographic Location Issues Irrigation rate Edwards Aquifer (30 TAC Chapter 213) Lake rules (30 TAC Chapter 311)
12. TECHNICAL REVIEW: AVOID COMMON ERRORS No discussion of Other Requirements Inadequate buffer zone map: should be 8.5 X 11, black and white, not google maps Inadequate pollutant analysis: incomplete, old, wrong units, no lab sheets No justification for unbuilt phases or flow request Treatment process, treatment unit dimensions, process flow chart incomplete
13. Compliance history period is 5 years from the date the application was received If you have an Admin Order or more than 10 NOVs, you will be contacted by the permit coordinator for more information on the issues that caused the Order or violations High compliance history rating requires no further review Satisfactory compliance history may require the Executive Review Committee if there are Admin Orders or more than 10 Notice of Violations Poor compliance history requires the Executive Review Committee and other steps to make sure the issues have been resolved Special language may be added as a result of the ERC COMPLIANCE HISTORY REVIEW No Admin Orders & <10 NOVs Admin Orders or ≥10 NOVs
14. BUFFER ZONE MAP EXAMPLE Buffer zones are required for: Separation from public and private water sources Nuisance odor control A good buffer zone map: Is on one 8.5x11 inch sheet of paper Is in black and white (Google maps don’t copy well) Shows all adjacent property owners Shows all nearby public and private water supplies Shows the distance from the adjacent property or water supply to the nearest treatment unit Shows how the buffer zones are met for each adjacent property (legal restrictions, a nuisance odor control plan, etc.) See 30 TAC §309.13 Note that on-site lift stations are considered treatment units for buffer zone purposes.
15. ANTIBACKSLIDING BACKSLIDE WITH CARE Federal regulations - no permit reissued with less stringent conditions Federal Anti-backsliding regulations (40 CFR Part 122.44 (l)(2)(i) Amendment applications are compared to federal Antibacksliding regulations Circumstances where a less stringent permit may be issued: New information Changed conditions Recent plant performance BACKSLIDING
16. TCEQ/EPA BACTERIA LIMITS Bacteria limits in all discharge permits Typically 126 CFU per 100 mL E. coli (freshwater) Typically 35 CFU per 100 mL enterococci (saltwater) TMDLs may require tighter bacteria limits Monitoring frequencies for bacteria are given in 30 TAC 319.9, Table 2) Larger facilities sample more often than smaller systems UV system sample more often than natural systems Natural systems sample more often than chlorine systems
17. Geometric mean sampling Why a geometric mean? How does a geometric mean help? Bacteria hold time issues Pond bacteria issues Wetland bacteria issues GEOMETRIC MEAN FOR BACTERIA
18. State policy prefers regional or area-wide wastewater treatment systems over a large number of smaller treatment systems. New and expanding plants contact existing wastewater treatment providers Provide a 3 mile radius map from the point of discharge that lists all permitted municipal facilities or collection systems CCN issues (512-239-4691) REGIONALIZATION
19. Ask yourself or an expert: Is it good for my treatment process? Do I have organic capacity? Accepting wastes can harm your treatment process. Be aware of the risks before you accept wastes like: Domestic septage (septic tanks) or chemical toilet waste Domestic WWTP biosolids Grit or grease Brewery, bottling, and food processing wastewater Animal feed or animal processing wastewater BEFORE ACCEPTING WASTE…
20. Lab tests must be able to give results at or below the minimum analytical level (MAL) The next presenter will discuss recent MAL changes MAL UPDATES
21. DRAFT PERMIT PACKAGE Draft Permit Package Cover Letter Public Notice (NAPD) Statement of Basis Fact Sheet Draft Permit
22. KNOWING YOUR DRAFT PERMIT Draft Permit Authorization Page (review carefully) Effluent Limits (review carefully) Standard Provisions Sludge Provisions Other Requirements (review carefully) Pretreatment & Biomonitoring (review carefully)
23. Part II – General Permitting Information Types of Applications Permit Classifications TLAPs 210 Reuse PART II – GENERAL PERMITTING INFORMATION
24. TYPES OF APPLICATIONS New* Brand new facility Expired permits re-apply as new facilities Requires additional mailed notice to adjacent landowners and landowners for one mile downstream Renewal Continue an existing authorization Can include a minor amendment Amendment Major Amendment* – substantially change or relax the permit (requires additional mailed notice to adjacent landowners and landowners for one mile downstream) Minor Amendment – update/change permit without relaxing the permit *Requires additional notice to adjacent and downstream landowners
25. PERMIT CLASSIFICATIONS Minor < 1.0 MGD Standard pollutant screening Standard pretreatment requirements (for POTWs) Major ≥ 1.0 MGD Full pollutant screening Biomonitoring Possibly expanded pretreatment
26. TPDES v. TLAP TPDES v. TLAP Texas Pollutant Discharge Elimination System (TPDES) permits allow discharge to surface waters (creeks, streams, lakes, etc.). Texas Land Application Permit (TLAP) permits allow disposal by irrigation for beneficial use or by evaporation. TLAP permits prohibit discharge to water in the state. The TPDES permit program is a federally delegated program with U.S. EPA oversight. The TLAP permit program is a state-only permit program.
27. TYPES OF TLAP PERMITS Four Types of TLAPs Irrigation (30 TAC, Ch. 309.20) Subsurface disposal (30 TAC, Ch. 309.20) Subsurface area drip dispersal (30 TAC, Ch. 222) Evaporation (30 TAC, Ch. 309.20) Maximum application rate in acre-ft/yr/acre or gal/sq-ft/day. Storage requirements Water balance
28. TLAP REVIEW Water Quality Assessment Team reviews new and amended permits Groundwater impact evaluation Soil analysis Application rate and storage requirements are determined by a water balance calculation Make sure your water balance assumptions reflect real life condidtions Case-by-case review of renewal applications
29. TLAP v. REUSE AUTHORIZATION TLAP Dedicated disposal site Permittee owns/leases land Requires permit (330 days) Reuse (210) At user’s demand Permittee does not control land Attached to existing TPDES/TLAP permit (30 days) For more information about Chapter 210 reuse authorizations, refer to the presentation “Reuse of Domestic Reclaimed Water” as Presented by Louis C. Herrin, III.
30. Dechlorination changes pending – see Water Quality Stakeholders webcasts Application revisions pending CHANGES TO WATCH FOR
31. PRESENTATION SUMMARY Different TCEQ sections work together to issue a permit The applicant can help expedite the process Comments may add significant time to permit processing TCEQ website has many helpful resources 210 Reuse authorization is in addition to a permit Bacteria limits are now part of every domestic discharge wastewater permit
32. CONTACT INFORMATION Dex Dean Dex.Dean@tceq.texas.gov 512-239-4671
33. ANY QUESTIONS?
34. Supplemental Information SUPPLEMENTAL INFORMATION The following slides provide additional information and resources that was not part of the live presentation.
35. PROGRAM LOCATION QUICK REFERENCE The TCEQ's Office of Water handles wastewater permits. The Office of Water and the Chief Clerk's Office are in different branches of the TCEQ. The Office of Water is under the Executive Director. Other Offices in this branch include the Office of Administrative Services, Chief Engineer’s Office, Office of Compliance and Enforcement, Office of Legal Services, Office of Air, and Office of Water.
36. PROGRAM LOCATION QUICK REFERENCE Office of Water Water Availability Water Quality Planning Water Supply Water Quality Permits Industrial Municipal (Domestic) Stormwater Agriculture
37. HELPFUL RESOURCES TCEQ website: http://www.tceq.state.tx.us Keyword/forms search (database, Spanish templates, 10053, 10054, municipal wastewater permits, etc.) Central Records 512-239-2900 Chief Clerk’s Office: 512-239-3300 Water Quality Division: 512-239-4671 Regional Offices
38. GET FORMS ON THE WEB To access the forms: (1) open the TCEQ webpage, (2) click on the ‘Forms’ link, and (3) enter the form number in the ‘Forms Search’ page. The forms page can also be searched by keyword or subject. 1 3 2
39. KEEPING TRACK OF PERMIT STATUS PART 1 TCEQ Homepage Find the Status of Permit/License
40. KEEPING TRACK OF PERMIT STATUS PART 2 Status of a Stormwater and Wastewater Applications and Specifications
41. KEEPING TRACK OF PERMIT STATUS PART 3 Status of Water Quality Individual Permit Applications
42. KEEPING TRACK OF PERMIT STATUS PART 4 Search for application by State Permit No.
43. KEEPING TRACK OF A PERMIT STATUS PART 5 Search results will show you: Where the permit is in the permitting process Who the Admin Reviewer is Who the Permit Coordinator is If there have been any public comments
44. PERMIT SEARCH PART 1 Use permit search tab Use Advanced Search Option
45. PERMIT SEARCH PART 2 Used the Advanced Search option to: Find a group of specific type of permits Permits within a certain region, county, etc Active/expired
46. COMMISSIONERS’ INTEGRATED DATABASE PART 1
47. COMMISSIONERS’ INTEGRATED DATABASE PART 2
48. COMMISSIONERS’ INTEGRATED DATABASE PART 3